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In response to respondent’s July 7, 2004, 30-day letter,
petitioners sent a letter, dated July 24, 2004, along with their
check in the amount of $1,153.23 to respondent. In that letter,
petitioners explained that the $8,448 claimed contribution
carryover deduction was an error attributable to Turbotax
software. In a September 7, 2004, letter, respondent answered
petitioners’ July 24 letter, and among other matters, advised
petitioners that the changes to their 2001 tax return resulted in
a total tax obligation (apparently including interest to August
6, 2004) of $2,528.77. Respondent, on November 5, 2004, sent
petitioners a statutory notice of deficiency for their 2001 year
determining an income tax deficiency in the amount of $2,327.40.
Petitioners thereafter commenced this proceeding.
OPINION
The controverted item in this case is an $8,448 contribution
carryover deduction. Petitioners do not contend that they were
entitled to that deduction. Instead, they make a collateral
attack, contending, alternatively, that respondent’s deficiency
notice was invalid, or that respondent agreed to a lesser
deficiency, or that the tax preparation software manufacturer is
liable.
Petitioners’ first argument is that the 2001 notice of
deficiency is invalid. Petitioners argue that the notice has
errors and does not reflect the correct amount of income tax
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